Document 857nqjGGZ0en7J16d7BEadVDK

FILE NAME Rogers Corporation ROG DATE 1987 Mar 22 DOC ROG072 DOCUMENT DESCRIPTION Memo RE Interpretation of OSHA Asbestos Regulation 22 March 87 Subject From To Interpretation of OSHA Asbestos Regulation - MRBeauregard MMD WAHayes RJMikulak MJDeLassus ACBelden JPRispoli LPMacVane REQuaranto AJEsposito FLMorse ARChambers - MMD HHBirkenruth - Group RFLee WJWhiteley TBGauthier - Corp Engineering RCBerry - Corp Technology The Department of Labor Occupational Safety and Health Administration published revised regulations for asbestos exposure on Friday 20 June 1986 in the Federal Register Volume 51 No. 119. No action was taken at MMD on these regulations based on information that these were on hold pending litigation Per OSHA this regulation became law 20 July 86. The only litigation pending relates to the Construction Standard not the Industry Standard The following is my interpretation of the regulations and the action required to bring MMD into compliance A. Summary 1. We are not in compliance with any section of these regulations We do have parts of some sections in place 2 The action level for asbestos in 0.1 fibers per cubic centimeter cc of air This level triggers exposure monitoring worker training medical monitoring and other requirements ...The PEL for asbestos is 0.2 fibers per cubic level triggers restricted areas respiratory clothing and other requiremnts centimeter of air This protection protective 4. Compliance dates we have missed Exposure Monitoring * Employee Information and Training Regulated Areas - Respiratory Protection - Medical Surveillance 20 Oct 86 20 Oct 86 17 Nov 86 17 Nov 86 17 Nov 86 * Modifications to our existing programs are required to bring us into compliance 5 Compliance dates upcoming 0 _ * o Bring lunchroom and changerooms into compliance Engineering and work practice changings bringing exposure level below 0.2 cc where possible 20 July 87 20 July 88 Rogers Dusto - 001834 -2- B. Exposure Monitoing required if asbestos levels are above 0.1 cc 1. Monitoring must take samples representing shift exposures for each shift for each employee in each job classification in each work area We appear to be in compliance as far have never monitored the Staff Group areas as the Operating Group but we working in asbestos regulated Monitoring must be done at six month maximum intervals or whenever there has been a process procedure or personnel change Monitoring was done the week of 16 March 87. since Oct. 85 It had not been done Affected employees or their representatives must be offered the opportunity to observe the monitoring All affected employees must be notified of monitoring results within 15 days of receipt of the results 5. Tim Gauthier has indicated that we are in compliance with the method requirements for monitoring Employee Information and Training required if levels are above 0.1 cc 1 Training must be done before an individual is assigned into an area and yearly afterwards 2. Training must include Health effect of asbestos exposure Relationship between smoking and asbestos exposure in producing lung cancer Procedures on use and storage of asbestos to minimize exposure oc.oO Storage locations and quantities Engineering controls e.g. dust collectors in place and planned Purpose and proper use of respirators and protective clothing co o Purpose and Purpose and A review of description of monitoring description of medical surveillance this OSHA regulation Affected employees have right to a copy of the standard if requested Signs with specific warnings must be placed outside regulated areas Labels with specific warnings must be placed on all WIP Rogers Dusto - 001835 -3- D. Regulated Areas required if levels are above 0.2 cc 1. Must be demarcated from the rest of the workplace 3. Access limited to authorized persons Each person entering the area must wear a respirator Employees cannot eat drink smoke chew tobacco or gum or apply cosmetics 5 Compressed air may not be used Engineering controls and operating procedures must be implemented to reduce exposures below 0.2 cc where feasible I believe we can install feasible controls to get below 0.2 cc Protective clothing must be worn in regulated areas These include oO Coveralls or similar body work clothing oO Gloves head coverings and foot coverings Face shields or vented goggles or safety glasses per 1910.133 Per Joe Hopkins of OSHA our piece uniforms meet the work clothing requirement and work boots meet the foot covering requirements as long as they are not worn home We must meet the head covering portion of this requirement E. Respiratory Protection required if levels are above 0.2 cc 1 Respirators must be worn by all persons entering regulated areas 2 mask respirators with efficiency filters such as the MSA Comfo II respirators we purchase meet the requirements However we must make available at least five different sizes from two manufacturers for each employee to select from Disposable masks are not acceptable The employer must provide a powered an employee choses this type purifying respirator whenever Employees must be fit tested in a complex procedure every six months There can be no facial hair between skin and the respirator Several employees will be required to modify or eliminate beards F. Medical Surveillance required if levels are above 0.1 cc 1 Preplacement examinations and periodic examinations are required Our program meets these requirements However we provide chest Rays much more frequently than required for most employees Only employees with 10+ years exposure who are over 45 must be filmed annually Employees with 10+ years exposure in the 35-45 age bracket must be filmed every two years All other employees every five years Rogers Dusto - 001836 -4- F. Medical Surveillance required if levels are above 0.1 cc - cont 2 An examination at termination of employment must be made available for any employee exposed to asbestos 3 Physician's written opinion must contain o Opinion on any detected medical conditions re) Any recommended limitations on the employee or the use of personal protective equipment G. Hygiene Facilities required if levels are above 0.2 cc 1. Changeroom required with two lockers for each employee These lockers must be separated to prevent contamination of street clothes by work clothing or protective equipment 2 Employer must ensure that employees shower at the end of the shift 3 Lunchrooms must be provided which have a positive pressure filtered air supply In my opinion the use of the outdoors our Milled Area lunchroom will meet this regulation room air conditioner and pulling air in from the with 4. Employees must vacuum themselves and wash their hands and face before entering the lunchroom H. Housekeeping required with any asbestos use 1 All surfaces must be kept free of asbestos containing dust and waste 2 Compressed air may not be used to blow off surfaces 3 Shoveling and dry sweeping are not permitted 4. Vacuums must be equipped with HEPA filters We must discontinue use of the Sears portable vacuums in No. 2 GLP and No. 1 Extrusion We meet this requirement with the central vacuums discharging into the dust collectors 5 containing waste including empty asbestos bags must be disposed in impermeable bags or containers Rogers Dusto - 001837 -5- I. Recordkeeping required with any asbestos use 1 Records must be kept on exposure measurements medical surveillance and training 2. Records must be kept for 30 years minimum 3 Records for exposure monitoring must included 0 Date of measurement C0 Operation involving exposure o 0 Sampling and analytical methods used and evidence of their Number duration and results of samples taken Type of respiratory protection worn Name social security number and exposure of employees accuracy We have records containing most of this information 4 Records on medical surveillance must include Name and social security number of the employee 0 Physician's written opinions Employee medical complaints related to asbestos exposure A copy of the information provided to the physician We have records containing most of this information J. Action Plan - will bring us into compliance within six weeks 1. Exposure Monitoring oO Complete monitoring of asbestos exposures MRBeauregard 17 April 87 Set up plan to monitor every six months MRBeauregard Sept 87 Employees notified of monitoring results REQuaranto 15 Days After Receipt 2. Employee Information and Training ce] Training oO Warning Signs oO Warning Labels FLMorse FLMorse FIMorse 17 April 87 17 April 87 8 May 87 Rogers Dusto - 001838 J. Action Plan - will bring us into compliance within six weeks 3. Regulated Areas o Monitor asbestos fiber levels at edges of work areas TBGauthier MRBeauregard 3 April 87 Based on results above determine whether isolation walls or demarcation lines on the floor are required MRBeauregard Design engineering controls to lower exposure levels below 0.2 cc ARChambers Enforce other aspects of regulated areas LPMacVane regulations for 24 April 87 20 July 88 17 April 87 Respiratory protection Selection and fit testing REQuaranto 1 May 87 o Enforcement of use JPRispoli ; After 1 May 87 Medical Surveillance -- Bring us into compliance REQuaranto Hygiene Facilities 0 Plan for upgrading changerooms and lunchroom MRBeauregard fe) Upgrade changerooms and lunchrooms MRBeauregard 0 Enforce showering at shift and vacuuming washing before entering lunchrooms JPRispoli 17 April 87 10 April 87 20 July 87 1 May 87 Housekeeping 0 Bring us into compliance JPRispoli 1 May 87 Rogers Dusto - 001839 -7- J. Action Plan - will bring us into compliance within six weeks -- cont 8. Recordkeeping re) Pull together existing records into a central file REQuaranto 24 April 87 o Set up forms and formats for future records REQuaranto 1 May 87 o Keep records up to date REQuaranto After 1 May 87 bah Rogers Dusto - 001840